© 2015 paypal. all rights reserved. paypal (europe) s.à r ... · payment processing globally....

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared As of: July 1, 2015 1 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A. Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed Payment Processors HSBC Bank Plc (UK, Ireland), HSBC Merchant Services LLP (UK), Bank of America (UK, USA, Italy, and India), Discover Financial Services (USA), JPMorgan Chase Bank (UK, USA), BNP Paribas (France), Netgiro (Sweden), StarFinanz (Germany), Wells Fargo (Ireland, USA), American Express (USA), National Westminster Bank PLC (UK), OmniPay Limited (Ireland), Australia and New Zealand Banking Group Limited (Australia), ANZ National Bank Limited (New Zealand) and Transaction Network Services (UK) Limited (UK) To allow payment processing settlement services, and fraud checking. Name, address, details of user funding instruments, and details of payment transactions Deutsche Bank AG (Germany, Netherlands, France, Spain) To allow the processing of direct debits in Germany, Netherlands, France and Spain. Name, date of transaction, amount, currency and user’s bank account information. Royal Bank of Scotland plc (UK) (“RBS”) To allow payment processing and dispute handling for transactions of PayPal users when those users transact with a merchant who uses the PayPal service via the RBS service. All account information except details of user financial instruments. Visa Europe Ltd (UK) including Visa’s VMAS To share risk and All account details of

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Page 1: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

1 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Payment Processors

HSBC Bank Plc (UK, Ireland), HSBC Merchant

Services LLP (UK), Bank of America (UK, USA,

Italy, and India), Discover Financial Services

(USA), JPMorgan Chase Bank (UK, USA), BNP

Paribas (France), Netgiro (Sweden), StarFinanz

(Germany), Wells Fargo (Ireland, USA),

American Express (USA), National Westminster

Bank PLC (UK), OmniPay Limited (Ireland),

Australia and New Zealand Banking Group

Limited (Australia), ANZ National Bank Limited

(New Zealand) and Transaction Network

Services (UK) Limited (UK)

To allow payment

processing

settlement

services, and fraud

checking.

Name, address,

details of user funding

instruments, and

details of payment

transactions

Deutsche Bank AG (Germany, Netherlands,

France, Spain)

To allow the

processing of

direct debits in

Germany,

Netherlands,

France and Spain.

Name, date of

transaction, amount,

currency and user’s

bank account

information.

Royal Bank of Scotland plc (UK) (“RBS”)

To allow payment

processing and

dispute handling

for transactions of

PayPal users when

those users

transact with a

merchant who

uses the PayPal

service via the

RBS service.

All account information

except details of user

financial instruments.

Visa Europe Ltd (UK) including Visa’s VMAS To share risk and All account details of

Page 2: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

2 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

system; Mastercard International Incorporated.

(USA) including Mastercard’s MATCH system

fraud information in

the mandatory

credit card

company’s

database regarding

the conduct of a

merchant’s

account thereby

reducing exposure

to fraud and

breaches of

scheme rules and

standards.

merchant account, and

circumstances and

conduct of the account

Global Payments UK LLP (UK)

To allow payment

processing, fraud

checking and

dispute handling

for transactions of

PayPal users when

those users

transact with a

merchant who

uses the PayPal

service via the

Global Payments

service.

Name, address,

details of user funding

instruments and

details of payment

transactions

WorldPay (UK) Limited, Worldpay AP Limited,

(UK) Worldpay . (The Netherlands)

To allow payment

processing, fraud

checking and

dispute handling

for transactions of

PayPal users when

those users

All Account

information except

details of user financial

instruments

Page 3: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

3 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

transact with a

merchant who

uses the PayPal

service via

Worldpay service.

American Express Travel Related Services

Company, Inc.

To allow payment

processing

settlement

services, and fraud

checking.

Unique Seller ID.

Seller MCC

Seller DBA

Authorized signer

Seller address, postal

and country code

Seller phone number

Seller email address

Seller URL

Date of birth (for sole

proprietors only)

For non-publicly

traded Sponsored

Merchants only (e.g.

privately held

company, sole

proprietor), the

following information

for a Significant Owner

(as defined below):

First and last

name

Home

address,

postal code

and country

code

SSN or date of

Page 4: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

4 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

birth

Significant owner

means an individual

who has 25% or

greater ownership of a

business.

Unique seller ID*

Sponsored Merchant

MCC

Sponsored Merchant

DBA

Sponsored Merchant

location (city, street,

postal code and

country code)

Sponsored Merchant

phone number

JPMorgan Chase Bank, N.A. London Branch

Anti-money

laundering,

sanctions list

checking and

compliance checks

Name of merchant,

country of domicile,

and business activity

Adyen B.V. (Netherlands)

To allow payment

processing and

settlement services

globally.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Allied Irish Bank PLC (UK)

To allow payment

processing and

settlement services

in Europe.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Page 5: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

5 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Cardinal Commerce Corporation (US)

To facilitate

3DSecure

checking for

payment

processing

globally.

Standard transaction

data for 3DSecure.

Coinbase Inc. (US)

To allow payment

processing and

settlement services

globally.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Heartland Payment Systems, Inc. (USA)

To allow payment

processing and

settlement services

in the United

States.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Merchant e-Solutions, Inc. (US)

To allow payment

processing and

settlement services

in the United

States.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Moneris Solutions Corporation (Canada)

To allow payment

processing and

settlement services

in Canada.

Name, address,

details of payment

instruments, and

details of payment

transactions.

National Australia Bank Ltd. (Australia)

To allow payment

processing and

settlement services

in Australia.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Network Merchants, LLC. (US); Network To allow payment Name, address,

Page 6: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

6 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Merchants Inc. (US) processing and

settlement services

in the United

States.

details of payment

instruments, and

details of payment

transactions.

Stockholms Enskilda Bank AB (Sweden)

To allow payment

processing and

settlement services

in Europe.

Name, address,

details of payment

instruments, and

details of payment

transactions

WorldPay, Inc. (US); WorldPay Ltd. (UK)

To allow payment

processing and

settlement services

globally.

Name, address,

details of payment

instruments, and

details of payment

transactions.

Audit

PricewaterhouseCoopers Sàrl (Luxembourg)

To test PayPal’s

Anti Money

Laundering (AML)

and Know Your

Customer (KYC)

controls and to

carry out

professional

auditing services

for PayPal Inc. and

its subsidiaries.

For a sample of

individual customer

accounts:

name, PayPal account

number (Customer

ID), total amount

received on the

PayPal account, total

amount sent from the

PayPal account, type

of PayPal account,

and, as the case may

be, any other relevant

account information.

Customer Service Outsourcing

Sutherland Global Services Inc. (USA and

Philippines), Sitel GmbH (Germany), Transcom

To allow telephone

and email

Name, address, phone

number, email

Page 7: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

7 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Worldwide SAS (France, Tunisia), Transcom

Worldwide France SAS (France), Transcom

Worldwide SpA (Italy), Competence Call Center

Leipzig GmbH (Germany), Convergys Customer

Management Group Inc. (USA), Arvato Direct

Services GmbH (Germany) and Concentrix

Europe Limited (UK)

customer support

services.

addresses, truncated

and limited or full

funding source

information (case

dependent), funding

source expiration

dates, type of PayPal

account, proof of

identity, account

balance and

transaction

information, customer

statements and

reports, account

correspondence,

shipping information,

and promotional

information.

Nuance Communications Inc. (USA)

To calibrate and

optimise speech

recognition

performance for

telephone

customer support

services.

Recordings of a

sample of customer

support telephone

calls, which may

include any or all

account information

transmitted during the

call.

ICT Group Inc. (US)

To perform and

facilitate telephone

customer support.

Name, address, phone

number, and PayPal

account number.

Lithium Technologies Inc. (USA)

To provide

member-to-

member platform

Name, email address,

PayPal single sign on

ID (PayPal SSN ID)

Page 8: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

8 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

services and

customer service

on our customer

community

platforms.

Attensity Europe GmbH

To provide

customer services

arising from

customer contacts

to PayPal on social

media channels.

Information provided

by the customer via

social media channels

which may include

name, address, phone

number, email

addresses, social

media user names,

truncated and limited

or full funding source

information (case

dependent), funding

source expiration

dates, type of PayPal

account, proof of

identity, account

balance and

transaction

information, customer

statements and

reports, account

correspondence,

shipping information,

and promotional

information.

ILinc Communications, Inc. (USA)

To provide

webinars (online

seminars) to

Name, email address

of merchants

Page 9: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

9 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

merchants on

ILinc’s platform.

ePerformax Contact Centers & BPO (USA),

Genpact International Inc. (USA), LatentView

Analytics Pte. Ltd

To provide

customer services

regarding

payments globally.

Name, address, phone

number, email

addresses, truncated

and limited or full

funding source

information (case

dependent), funding

source expiration

dates, type of PayPal

account, proof of

identity, account

balance and

transaction

information, customer

statements and

reports, account

correspondence,

shipping information,

and promotional

information.

Authentify Inc.

Telephony based

authentication

service

Mobile and land-line

phone numbers

CallPoint New Europe AD dba TELUS

International Europe (Bulgaria)

To operate

refunded returns

service.

Name, email address,

PayPal transaction ID,

return information

(returned item

category, reason for

return, amount of

return, currency,

Page 10: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

10 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

country of return, type

of return) and shipping

documentation

evidence.

Key Performance Group SAS, France

Administration of

PayPal member

referral program

First name, last name,

email, customer ID,

transaction information

related to referral

rewards

New Relic, Inc. (US)

To provide

analytics allowing

us to troubleshoot

errors in the

service globally.

Log Data and

Aggregated data on

the service

performance.

PagerDuty, Inc. (US)

To alert on-call

technicians that an

email has arrived

globally.

Subject of the Email at

issue.

Sumologic, Inc. (US)

To provide

analytics allowing

us to troubleshoot

errors in the

service globally.

Log Data and

Aggregated data on

the service

performance.

Credit Reference and Fraud Agencies

Please note that in addition to the stated purposes below, PayPal uses your personal information to

detect, prevent, and/or remediate fraud or other illegal actions, or to detect, prevent or remediate

violations of policies or applicable user agreements.

CRIF (Italy), Cerved B.I (Italy), Coface (France),

Synectics Solutions Limited (UK), MCL Hunter

(UK), GB Group plc (UK), Graydon (UK), Capita

Plc (UK),UK Data Limited (UK), ICC Information

To verify identity,

verify linkage

between a

customer and its

Name, address, phone

number, email

address, date of birth,

length of time at

Page 11: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

11 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Limited (UK), Payment Trust Limited (UK),

192.com (UK), 192.com Limited (UK), i-CD

Publishing (UK) Limited (UK), Experian

Netherlands BV (Netherlands), Experian Bureau

de Credito SA (Spain), Informa D&B SA (Spain),

and CRIBIS D&B S.r.l. (Italy).

bank account or

credit/debit card,

assist in making

decisions

concerning a

customer’s credit

worthiness

(including without

limitation, in

relation to credit

products offered by

PayPal), carry out

checks for the

prevention and

detection of crime

including fraud

and/or money

laundering, assist

in debt recovery,

manage PayPal

accounts and

undertake

statistical analysis,

undertake research

and testing as to

appropriateness of

new products and

services and

system checking.

Please note that

data disclosed to

these agencies

address, proof of

identity, legal form,

length of time in

business, company

registration number,

VAT number, funding

instrument including

bank account and

credit /debit card

details (if appropriate)

and relevant

transaction information

(if appropriate).

Page 12: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

12 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

may be retained by

the applicable

credit reference

and fraud agency

for audit and fraud

prevention

purposes.

Callcredit plc. (UK) including the SHARE

database administered by Callcredit, Experian

Limited (UK) including databases administered

by Experian used for consumer and commercial

referencing including CAPS credit searches and

CAIS credit account performance data, Equifax

Ltd (UK) including the Insight database

administered by Equifax, Dun & Bradstreet

Limited (UK)

To verify identity,

verify linkage

between a

customer and its

bank account or

credit/debit card,

make decisions

concerning a

customer’s credit

worthiness

(including without

limitation, in

relation to credit

products offered by

PayPal), carry out

checks for the

prevention and

detection of crime

including fraud

and/or money

laundering, assist

in debt recovery,

manage PayPal

accounts and

undertake

statistical analysis,

Name, address, phone

number, email

address, date of birth,

length of time at

address, proof of

identity, legal form,

length of time in

business, company

registration number,

VAT number, funding

instrument including

bank account and

credit /debit card

details (if appropriate),

relevant transaction

information (if

appropriate), account

balance, all

information supplied

and used for your

application for the UK

products “Website

Payments Pro”,

“Virtual Terminal” and

“PayPal Here” and the

financial instrument

Page 13: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

13 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

undertake research

and testing as to

appropriateness of

new products and

services and

system checking.

For users of the

UK products

“Website

Payments Pro”,

“Virtual Terminal”

and “PayPal Here”

and UK merchants

only:

• to report defaults

and supply monthly

account

performance

information, where

the account shows

an amount owing

to us (reflected as

a negative

balance) for three

or more

consecutive

months, to the

databases of these

third parties; and

• for the purposes

set out in section 8

of this Privacy

used to pay for your

PayPal Here- enabled

device.

Page 14: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

14 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Policy.

Please note that

data disclosed to

these agencies

and databases

may be:

• retained by the

applicable credit

reference agency

or database for

audit and fraud

prevention

purposes;

• disclosed to other

financial

institutions for the

purpose of gauging

creditworthiness;

and

• transferred

outside of the EU

and on a global

basis.

CIFAS (UK) and the CIFAS database

For users with UK

PayPal accounts

only: to prevent

and detect fraud

(which may include

checking details on

job applicants and

employees and on

proposals and

All account details and

circumstances of the

conduct of the account

Page 15: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

15 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

claims for all types

of insurance).

Please note that

data disclosed to

this database may

be:

• retained by the

database for audit

and fraud

prevention

purposes;

• disclosed to other

financial

institutions for the

purpose of fraud

prevention and

detection (including

to prevent money

laundering) for

example, when

checking details on

applications for

credit and other

facilities, managing

credit and credit

related accounts or

facilities,

recovering debt,

checking details on

claims for

insurance and

Page 16: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

16 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

checking details of

job applicants or

employees;

• used to

determine your risk

profile and for

cooperation with

the relevant

authorities in

compliance with

the requirements of

the Luxembourg

Law of 5 April 1993

on the financial

sector and laws

relating to the

prevention of

money laundering,

terrorism and fraud

(excluding the

treatment of

personal data in

relation to solvency

of the persons

referred to in article

14(1)(d) of the

Luxembourg Law

of 5 April 1993 on

the financial

sector); and

• transferred

outside of the EU

and on a global

Page 17: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

17 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

basis.

DueDil Limited (UK)

To receive

business

information for risk

assessment, and

compliance with

anti-money

laundering

requirements, such

as establishing the

corporate structure

and beneficial

ownership.

Company registration

number, name and

address of business,

name, address, date

of birth of directors.

Creditsafe USA Inc. (USA)

To receive

business

information for risk

assessment, and

compliance with

anti-money

laundering

requirements, such

as establishing the

corporate structure

and beneficial

ownership.

Company registration

number, name, and

address of business,

name, address, date

of birth of directors

Deltavista GmbH (Germany)

Establish risk

associated with

address, identity;

assist in making

decisions

concerning a

customer’s credit

Name, address, date

of birth, email address

Page 18: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

18 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

worthiness;

research and

testing as to

appropriateness of

new products and

services.

Accumio Finance Services GmbH (Germany),

CEG Creditreform Boniversum GmbH

(Germany), Bürgel Wirtschaftsinformationen

GmbH & Co. KG (Germany)

To verify identity

and address and

retrieve contact

phone numbers

and addresses,

establish risk

associated with

address, identity;

research and

testing as to

appropriateness of

new products and

services.

To assist in making

decisions

concerning the

credit worthiness of

consumers (if they

have a German

PayPal account

and have

specifically

consented to such

check) and

merchants,

including without

limitation, in

Name, address, date

of birth, email address,

account status,

account balance, and

in case the transfer of

such information is

legally justified, also

certain information on

negative account

performance of a

customer with a

German PayPal

account, for which

PayPal has requested

a creditworthiness

check from the

respective database.

Page 19: © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r ... · payment processing globally. Standard transaction data for 3DSecure. Coinbase Inc. (US) To allow payment processing

List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

19 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

relation to credit

products offered by

PayPal and

offering direct debit

payments as

payment method.

The

creditworthiness

scores that we

request from these

agencies that

include scores that

are calculated

according to

mathematical-

statistical

procedures.

Please note the

fact that PayPal

requested such

information, and

any negative

account

performance data

disclosed to these

databases in

relation to

customers who

have a German

PayPal account

may potentially be:

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

20 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

• retained by the

database for audit

purposes and for

scoring of such

customer’s

creditworthiness;

• any such score

may be disclosed

to other third

parties for the

purpose of gauging

creditworthiness.

and

• transferred

outside of the EU

and on a global

basis.

SCHUFA Holding AG (Germany), infoscore

Consumer Data GmbH (Germany)

To verify a

customer's identity

and address, carry

out checks for the

prevention and

detection of failing

direct debit

payments, and of

crime including

fraud and/or

money laundering,

including checks

on the linkage of

the customer and

its bank account, to

help determine

Name, address, email

address, date of birth,

gender, bank account

details, information on

failed direct debit

payments from a bank

account (without

linkage to the identity

of the customer), and

in case the transfer of

such information is

legally justified, also

certain information on

negative account

performance of a

customer with a

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

21 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

creditworthiness of

consumers (if they

have a German

PayPal account

and have

specifically

consented to such

check) and of

merchants, and for

research and

testing as to

appropriateness of

products and

services.

The

creditworthiness

scores that we

request from these

agencies include

scores that are

calculated

according to

mathematical-

statistical

procedures.

Please note the

fact that PayPal

requested such

information, and

any negative

account

performance data

disclosed to these

German PayPal

account.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

22 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

databases in

relation to

customers who

have a German

PayPal account

may potentially be:

• retained by the

database for audit

purposes and for

scoring of such

customer’s

creditworthiness;

• any such score

may be disclosed

to other third

parties for the

purpose of gauging

creditworthiness

and

• transferred

outside of the EU

and on a global

basis.

Further, in relation

to customers who

have a German

PayPal account,

the information on

a failed direct debit

payment may be:

• retained by the

infoscore database

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

23 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

for audit purposes;

and

• (without linkage

to the customer’s

identity) disclosed

to other third

parties for the

purpose of

preventing failed

direct debit

payments.

Creditreform Berlin Wolfram KG (Germany),

Verband der Vereine Creditreform e.V.

(Germany)

To determine

creditworthiness of

merchants.

Name, address, email-

address.

World-Check (UK) To verify identity.

All account

information.

Global Data Corporation (USA)

To verify identity,

carry out checks

for the prevention

and detection of

crime including

fraud, research

and testing as to

appropriateness of

new products and

services.

Name, address, date

of birth, telephone

number, email address

RSA Security Inc. (USA) and RSA Security

Ireland Limited (Ireland) To verify identity.

All account

information.

ID Checker.nl BV (Netherlands) (Ireland)

To verify identity;

automatic data

extraction from

images of

Name, address, email

address, date of birth,

legal form, company

registration number,

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

24 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

documents, and

document

validation / forgery

detection.

Research and

testing as to

appropriateness of

new products and

services.

VAT number, proof of

identity, address,

ownership of a funding

instrument or other

documents requested

by PayPal and the

data contained therein

for Risk / Compliance/

Credit purposes.

Aristotle International, Inc. (USA) To verify identity.

Name, address, date

of birth

Acxiom Ltd (UK), Acxiom Deutschland GmbH

(Germany) and Acxiom France SAS (France) To verify identity.

Name, address, phone

number, email address

and date of birth.

Creditinfo Decision (Czech Republic) and

DecisionMetrics Limited (UK)

To assist with

PayPal’s

assessment of

merchant risk.

All merchant account

information.

ThreatMetrix Inc (USA)

To retrieve risk

information

regarding the IP

and device from

which you are

accessing PayPal,

research and

testing as to

appropriateness of

new products and

services.

IP and hardware

information about the

device (device ID)

TeleSign Corporation (USA)

To validate phone

numbers, research

and testing as to

Telephone number

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

25 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

appropriateness of

new products and

services.

AddressDoctor GmbH (Germany),

To re-structure

address data into

normalized format.

Name, address, email

address

Deutsche Post Direkt GmbH (Germany), AZ

Direct GmbH (Germany), Deutsche Post Adress

GmbH & Co. KG (Germany)

To validate and re-

structure address

data into

normalized format

and to verify name

and address.

Name, address, email

address

Mitek Systems Inc. (USA)

To validate images

of identity

documents and

research and

testing as to

appropriateness of

new products and

services.

Proof of identity,

details of bank

accounts and

credit/debit card

information

Jumio Inc (USA)

To capture and

validate proofs of

identity and

address

All data recorded on

the customer’s identity

and address

documents

Au10tix Limited (Cyprus), AuthenticID LLC

To verify identity;

automatic data

extraction from

images of

documents,and

document

validation / forgery

detection.

Name, address, email

address, date of birth,

legal form, company

registration number,

VAT number,

documents proving

identity and address,

ownership of a funding

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

26 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Research and

testing as to

appropriateness of

new products and

services.

instrument, or other

documents requested

by PayPal and the

data contained therein

for Risk / Compliance/

Credit purposes.

Telovia SA (Luxembourg)

Identity validation

and Know Your

Customer (KYC)

controls conducted

for anti money

laundering

purposes

Name, address, date

of birth, proof of ID

and address

Syniverse Technologies, LLC (USA)

Validate and apply

data quality checks

to phone numbers

(SMS message to

be sent to the

customer)

Name, address, phone

number.

Signicat AS (Norway)

To verify and

authenticate

identity

Name, address, date

of birth and e-id

reference number

BankersAccuity Inc. (USA)

Research and

testing as to

appropriateness of

new products and

services in relation

to the validation of

the account data

provided to us by

the user and

conversion of

Customer’s bank

account number and

sort code and / or

IBAN

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

27 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

national account

data information

into IBAN

ArkOwl LLC (USA)

To verify email

address Email address

Fraudscreen Ltd (UK)

To evaluate level

of fraud risk Name and address

LexisNexis, LexisNexis Risk Solutions UK

Limited (UK)

To assist with

customer

authentication

Name, address and

date of birth

Trustev Ltd (Ireland)

To establish

identity through

customer’s social

media data,

connections and

credentials

Name, address, date

of birth, email address

and account number

Tracesmart Ltd (UK)

To identify

customers and

assist with fraud

detection,

prevention, and or

remediation of

fraud, or other

illegal actions or to

detect, prevent or

remediate

violations of

policies or the

applicable user

agreements.

Title, name, address,

date of birth and

telephone number

Zoot Enterprises, Inc. (USA), Zoot Deutschland

GmbH (Germany), Zoot Enterprises Limited

To process

technical

All account information

and documents

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

28 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

(UK) applications and to

provide a data and

document gateway

for account review,

testing and vetting

purposes, and to

exchange user

information and

images of

documents proving

identity, address

and ownership of

funding instrument

with contracted

fraud and credit

reference

agencies. To also

aggregate data

from internal and

external data

sources and

provide statistical

analysis in order to

assess the risk of

fraud.

supplied by

customers, to include

information used to

provide identity and

address, ownership of

a funding instrument,

or other documents

requested by PayPal

and the data

contained therein for

Risk / Compliance /

Credit purposes. This

information may also

include IP addresses.

First Data Corporation (USA)

To process

merchant-initiated

and customer-

authorized

transactions and to

provide

account/card

processing

All account information

and documents

supplied by

customers, to include

information used to

provide identity and

address.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

29 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

services, to store

transaction,

payment and other

customer data

related to those

transactions.

La Banque de France (France), GB Group plc

(UK), SysperTec Communication (France)

Research and

testing as to

appropriateness of

new products and

services used to

establish risk

associated with

address, identity,

and associated

with a customer’s

credit worthiness.

Name, address, date

of birth, phone

number, email address

MaxMind, Inc. (USA)

To detect fraud.

Please note that

data disclosed to

this service

provider may be:

• retained by it for

audit and fraud

prevention

purposes;

• used by it for the

purpose of

optimising its fraud

detection services

provided to PayPal

and other third

parties; and

All account information

and IP address, credit

card information.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

30 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

• transferred

outside of the EU

and on a global

basis.

Future Route Ltd (UK)

To carry out

accounting data

analysis of our

commercial users

for real time credit-

risk evaluation.

Name, address, email

address and date of

birth.

Kount, Inc. (US)

To facilitate fraud

checking for

payment

processing

globally.

Name, address,

device fingerprint data,

details of payment

instruments, and

details of payment

transactions.

Artefacts Solutions LLC (US)

To detect fraud

and mitigate risk

related to

transaction

processing.

Truncated card

number, amount of

transaction,

chargeback ratio,

credit ratio, and

decline ratio.

Experian Information Solutions, Inc. (US)

To verify identity,

assist in making

decisions

concerning a

customer’s credit

worthiness, carry

out checks for the

prevention and

detection of crime

including fraud

and/or money

laundering.

Please note that

Name, address, social

security number, date

of birth, business

name, legal name of

business, tax ID,

business phone

number.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

31 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

data disclosed to

these agencies

may be retained by

the applicable

credit reference

and fraud agency

for audit and fraud

prevention

purposes.

Trulioo Information Services, Inc. (US)

To verify identity,

carry out checks for

the prevention and

detection of crime

including fraud

and/or money

laundering.

Please note that

data disclosed to

these agencies

may be retained by

the applicable

credit reference

and fraud agency

for audit and fraud

prevention

purposes.

Name, date of birth,

address, ID number (if

provided).

Financial Products

La Poste (France)

To resolve

technical issues

and user claims

(when PayPal is

being offered by

the merchant

through La Poste’s

Any Account

information necessary

to resolve the issue or

claim

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

32 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

payment solution).

Santander UK Cards Limited (UK)

To conduct joint

marketing

campaigns for

PayPal Credit, and

PayPal

MasterCard, risk

modelling, enforce

terms and

conditions for

PayPal Credit and

PayPal

MasterCard.

Name, address, email

address and account

information (including,

without limitation,

account status).

TSYS Card Tech Limited (UK), TSYS Managed

Services EMEA Limited (UK), PrePay

Technologies Limited (trading as PrePay

Solutions) (UK)

To conduct joint

marketing

campaigns for

PayPal pre-paid

card and risk and

fraud modelling

and to enforce

terms and

conditions for

PayPal prepaid

card.

Name, address, email

address, date of birth

and account

information.

Société Générale (France), La Banque Postale

(France), BNP Paribas (France) and Crédit

Mutuel (France)

Billing purposes.

Only for merchants

using PayPal through

the partner’s payment

solution: merchant ID,

number of PayPal

transactions,

transaction volume

with PayPal and, as

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

33 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

the case may be,

termination of the

PayPal account.

Findomestic Banca (Italy), Cetelem S.A., Cofidis

(France) and Cofinoga S.A. (France)

Registration of the

credit card issued

by the credit

company on the

user’s PayPal

account and the

processing of

funding requests

made by the same

user.

Name, email address,

date of birth (as the

case may be), credit

card number, expiry

date, three digit Card

Security Code (as the

case may be) and

amount of the funding

request and any

account information

necessary for fraud or

dispute resolution.

Total System Services, Inc. (USA)

To process

merchant initiated

and customer

authorised

payments

(including

customer direct

debit information)

to provide

account/card

processing

services, to store

transaction,

payment and other

customer data

related to those

transactions. To

provide call centre

Name, address, email

address, date of birth

(where required), all

account information

and documents

supplied by

customers, to include

information required to

prove identity and

address.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

34 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

services, card

printing, and

statement printing

services.

United Kapital Limited (UK) and United Kapital

Limited, LLC (USA)

To enable you (or

the merchant with

which you transact)

to use products

issued by United

Kapital with

PayPal.

Only for PayPal

merchants applying for

and using products

issued by United

Kapital Limited: Name,

business name,

address, date of birth,

copies of identification

documents, PayPal

identification

(merchant ID), email

address, phone

number, transaction

information (including,

without limitation,

number of PayPal

transactions and

transaction volume

with PayPal), length of

time as a PayPal user

and, as the case may

be, termination of the

PayPal account.

For customers of

those merchants:

transaction

information, name,

email address, phone

number, address and

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

35 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

PayPal identification

number.

Commercial Partnerships

Royal Mail Group Plc. (UK) and Pitney Bowes

Inc. (USA)

To provide

automated label

printing for sellers

using PayPal and

eBay to facilitate

postal and delivery

services, including

payment

reconciliation

services.

Name, address, email

address and postage

transaction amount.

Trustwave (USA)

To provide

customised

services and

assistance to

Merchants using

PayPal, and to

facilitate the

process of

becoming PCI DSS

compliant.

Name, email address

and PayPal account

number.

Stubhub Services S.à.r.l. (Luxembourg)

For the purposes

of its AML and

KYC requirements.

First and last name,

date of birth,

residential address,

nationality, national

ID/passport number

Marketing and Public Relations

Decipher Inc. (USA), Northstar Research

Partners (USA)

To conduct

customer service

surveys.

Name, email address,

type of account, type

and nature of the

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

36 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

PayPal services

offered or used, and

relevant transaction

information.

Ipsos Mori UK Limited (UK), Ipsos GmbH

(Germany), Ipsos SAS (France) and FactWorks

GmbH (Germany), TNS Deutschland GmbH

(Germany)

To conduct

customer service

and marketing

surveys.

Name, email address,

phone number, type of

account, type and

nature of the PayPal

services offered or

used, and relevant

transaction

information.

Adwise (France) and Axance (France)

To conduct

marketing surveys.

Name, email address,

phone number, type of

account, type and

nature of the PayPal

services offered or

used, and relevant

transaction

information.

BD Network Limited (UK), Tullo Marshall Warren

Limited (UK), and MyCash (France)

To develop and

execute customer

promotions.

Name, address and

email address.

Salesforce.com, inc. (USA)

To store merchant

contact information

as well as other

supporting

information about

the business

relationship.

Name, address, phone

number and email

address, business

name, URL PayPal

Account ID and other

supporting information

about the business

relationship, such as

(without limitation)

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

37 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

name of contact

person and contact

information at

merchant and/or

partner through which

merchant has been

onboarded, description

of products sold

through PayPal,

communication notes

and onboarding

information, internal

decisions about the

merchant, revenue

calculations and other

information on the

merchant’s business

as made available by

the merchant, and

information relevant

for special integrations

of merchants, name

and address of bank.

Daniel J Edelman Ltd (UK), I&E Consultants

(France), Grayling Communications Limited

(UK), Rock Communications (Italy), Fleisher

(Israel), Clue PR (Poland).

To answer media

enquiries regarding

customer queries.

Name, address, and

all customer account

information relevant to

customer queries.

Alchemy Worx Ltd (UK)

To allow

management

reporting of

marketing

campaigns.

Name, email address

and details of

customer campaign

interaction.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

38 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Carrenza Limited (UK)

To store user data

for marketing

campaigns.

Name, address, email

address, business

name, domain name,

account status,

account preferences,

type and nature of the

PayPal services

offered or used, and

relevant transaction

information.

1000Mercis SA (France) and 1000Mercis Ltd

(UK)

To store user data

to conduct

marketing

campaigns on

behalf of PayPal.

Name, email address,

phone number, type of

account, type and

nature of the PayPal

services offered or

used, and relevant

transaction

information.

A McLay & Company Limited (UK), TNT Post

Italia (Italy)

To assist in the

execution of offline

direct mail and

marketing

campaigns.

Name, address, email

address, business

name, domain name,

account status,

account preferences,

type and nature of the

PayPal services

offered or used, and

relevant transaction

information.

Datacolor Dialog-Medien GmbH (Germany),

MEILLERGHP GmbH (Germany) and W & J

Linney Ltd (UK)

To assist in the

execution of offline

direct mail and

marketing

Name, email address,

address, business

name, domain name,

account status,

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

39 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

campaigns. account preferences,

type and nature of

PayPal services

offered or used.

Medallia, Inc. (USA)

To conduct

customer service

surveys.

Name, email address,

type of account, type

and nature of the

PayPal services

offered or used, and

relevant transaction

information.

Endlichsommer- werbung in bester gesellschaft

mbh (Germany) and Crossover Communication

GmbH (Germany)

To assist in the

execution of offline

direct mail and

marketing

campaigns

Name, address,

business name, type

and nature of PayPal

services offered or

used.

optivo GmbH (Germany)

To send emails;

email marketing

Name of the merchant,

name of the contact

person, email address,

address, status, client

ID and shop system

Acxiom France SAS (France), Acxiom Ltd (UK)

and Acxiom GmbH (Germany)

To collect

additional user

information and

better target

marketing

campaigns.

Name, address, email

address, date of birth

and phone number.

Rapp (France), Antics (US), Partner Path

To develop,

measure and

execute marketing

campaigns.

Name, business

name, address and

registration number of

merchant/partner,

name, job, title, email

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As of: July 1, 2015

40 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

address, phone

number of merchant’s

contact person,

merchant website

URL, PayPAl account

number, third party

applications used by

the merchant,

behaviour on PayPal

Serviceswebsite.

DemandGen AG (Germany)

To execute e-mail

marketing

campaigns

Name, email address,

phone number, type of

account, type, and

nature of PayPal

Services offered or

used and relevant

transaction

information.

Business support services - b2s, SAS (France),

Foule Access SAS (France)

To store

merchants' contact

information for

marketing

communications to

those merchants.

Name of the merchant,

name of the contact

person, address, email

address, phone

number, merchant

website URL.

Consultix (France and Spain) and Quadro Srl

(Italy)

To host information

provided by

merchants and

display part of this

information on the

pages of the

PayPal website

listing websites

All information

provided by merchants

in connection with their

use of these pages of

the PayPal website

(including in particular

name of the merchant,

name of the contact,

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

41 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

accepting PayPal

and proposing

special offers to

PayPal users.

email address, logo

and information

relating to the

promotion(s) offered to

PayPal users).

Appnexus, Inc. (US), BlueKai, Inc. (US),

Conversant GMBH (Germany), Google Ireland,

Ltd. (Ireland),DoubleClick Europe Ltd (UK),

Adobe Systems Incorporated.

To execute

retargeting

campaigns in order

to deliver

personalised

advertising.

Anonymous ID

generated by cookies,

pixel tags or similar

technologies

embedded in

webpages

Criteo SA (France)

To execute

retargeting

campaigns in order

to deliver

personalised

advertising.

Anonymous ID

generated by cookies,

pixel tags or similar

technologies

embedded in

webpages and emails

delivered to users.

Linkedin Ireland Limited (Ireland)

To execute

retargeting

campaigns in order

to deliver

personalised

advertising.

Encrypted e-mail

address associated

with PayPal users

(without indicating

account relationship).

Conversant Inc. (USA)

To execute and

measure

retargeting

campaigns in order

to identify visitors

and redirect them

though

personalised

PayPal Account ID (as

appropriate) as well as

device ID used by a

specific person,

content of

advertisements to be

delivered and

segmentation in a user

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

42 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

advertising

campaigns.

group for

advertisement

purposes.

StrikeAd UK Ltd. (UK), Ad-x Limited (UK), Criteo

Ltd. (UK), Criteo Singapore Pte. Ltd

To execute and

measure

retargeting

campaigns in order

to segment users

for PayPal Here

marketing

campaigns.

Anonymous cookie ID,

Advertising ID, and

device ID to segment

user groups for

marketing purposes.

Fiksu, Inc. (US)

To execute and

measure

retargeting

campaigns in order

to segment users

for marketing

campaigns

involving PayPal

mobile

applications.

Device ID used for

Apple’s iOS operating

system when a user

installs an application,

signs up for the

PayPal Services, logs

in, checks in, or sets a

profile picture.

Nanigans, Inc. (US

To execute

retargeting

campaigns in order

to deliver

personalised

advertising.

Advertising ID

associated with Apple

iOS devices when a

user installs an

application,

relaunches an

application, signs up

for the PayPal

Services, logs in,

checks in, checks their

balance, saves an

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

43 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

offer, successfully

completes a

transaction, sets a

profile picture, or

makes other account

changes in or related

to the use of the

application.

Heaven SAS (France)

To execute

marketing

campaigns for

merchants.

Name of merchant,

merchant website

URL, description of

item purchased and

price of item.

Tenthwave Digital, LLC (USA)

To notify winners

and prize fulfillment

for winners of

survey

sweepstakes

Name and email

address, for

sweepstakes winners

and alternates only.

Sotiaf Telematiques Associes SAS (France)

To store user data

for marketing

campaigns and to

execute direct

marketing

campaigns.

Name, email address,

and phone number.

2engage (Germany) and Quo Vadis (Germany)

To conduct market

surveys.

Name, company

name, address,

telephone number,

domain name, e-mail

address, type and

nature of use of

PayPal services,

market segment and

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

44 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

generalised

categorisation of

company size and

information on

participation in earlier

surveys.

Facebook, Inc (USA), Facebook Ireland Limited

(Ireland) and Twitter, Inc. (USA)

To show relevant

advertisements to

Facebook and

Twitter users (as

the case may be).

Encrypted e-mail

address associated

with PayPal users

(without indicating

account relationship).

SurveyMonkey Spain, Sucursal em Portugal

(Portugal) and SurveyMonkey.com, LLC (USA)

To assist in

carrying out user

surveys.

Name, email address

and details of

customer campaign

interaction.

Marketing and Planning Systems, LLC. USA

(USA), Dynamic Logic, Inc. (USA), GfK Custom

Research LLC (USA), Millward Brown, Inc.

(USA) and Radius Global Market Research, LLC

(USA)

To conduct

customer service

and marketing

surveys

Name, email address,

type of account, type

and nature of PayPal

services offered or

used, and relevant

transaction information

Oracle America Inc. (USA),

Oracle Corporation UK Ltd

To develop,

measure and

execute marketing

campaigns.

Name, business

name, address and

registration number of

merchant, name, job

title, email address,

phone number of

merchant’s contact

person, merchant

website URL, PayPal

account number, third

party applications

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

45 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

used by the merchant,

behaviour on PayPal

website.

Nanigans, Inc. (USA), Fiksu, Inc. (USA), Ad- X

Limited (UK); Criteo Ltd. (UK), Criteo Singapore

Pte. Ltd

Help identify

behaviour in the

mobile app in order

to guide decision

about targeted

marketing; to help

efficiently handling

and optimising

mobile campaigns

on social networks

and elsewhere in

the web

Anonymous cookie ID,

Advertising ID, and

Device ID used by a

specific person, events

in the mobile app

about the use of the

mobile app by a

specific user

(including, without

limitation, login,

successful completion

of the transaction), but

no payment and

financial information

details.

Content of

advertisements to be

delivered to specific

users and, as

appropriate,

segmentation group to

which such person

belongs to for

advertisement

purposes.

Zeuner S.p.A. (Italy), Accueil Srl (Italy) and

CallCenterNet Italy s.r.l. (Italy)

To store

merchants' contact

information for

marketing

communications to

Name of the merchant,

name of the contact

person, address, email

address, phone

number, merchant

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

46 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

those merchants. website URL.

Purepromoter Ltd t/a Pure360

To send service

related and

(depending on opt-

in settings)

promotional SMS

messages to

PayPal users.

Mobile Number, name,

address, email

address, business

name, business

contact details,

domain name, account

status, account type,

account preferences,

type and nature of the

PayPal services

offered or used and

relevant transaction

and account

information

Iris (Germany)

To develop,

measure and

execute marketing

campaigns.

Name, business

name, address and

registration number of

merchant/partner,

name, job title, email

address, phone

number of merchant’s

contact person,

merchant website

URL, PayPal account

number, third party

applications used by

the merchant,

behaviour on PayPal

website.

OC&C Strategy Consultants Limited (UK)

To conduct market

research and

develop insight

Anonymized account

and transaction

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

47 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

information

Operational services

Kanzlei Dr. Seegers, Dr. Frankenheim & Partner

Lawyers (Germany, Austria, Switzerland),

Akinika Debt Recovery Limited (UK), Capita Plc

(UK), Compagnie Francaise du Recouvrement

(France), Clarity Credit Management Solutions

Limited (UK),; EOS Solution Deutschland GmbH

(Germany), EOS Aremas Belgium SA/NV

(Belgium), EOS Nederland B.V. (Netherlands),

Arvato Infoscore GmbH (Germany), Infoscore

Iberia (Spain), , SAS (France), Transcom

WorldWide S.p.A. (Italy), Transcom Worldwide

SAS (Tunisia), Intrum Justitia S.p.A. (Italy),

To collect debt.

Name, address, phone

number, account

number, date of birth,

email address,

account type, account

status, last four digits

of financial

instruments account,

sort code, account

balance, details of

account transactions

and liabilities, name of

funding source

provider and copies of

all correspondence in

each case relating to

amounts you owe (or

another person owes)

to us.

KSP Kanzlei Dr. Seegers (Germany), BFS Risk

& Collection GmbH (Germany); HFG

Hanseatische Inkasso- und Factoring-

Gesellschaft (Germany),BFS Risk and Collection

GmbH (Germany), Team 4 Collect (Spain),

Arvato Polska (Poland), BCW Collections Ireland

Ltd (Ireland), S.C. Fire Credit S.R.L. (Romania),

Gothia Financial Group AB (Sweden), Gothia AS

(Norway), Gothia A/S (Denmark), Gothia Oy

(Finland), Credit Solutions Ltd (United Kingdom).

To collect debt; to

handle reporting to

credit reference

agencies about

defaulting

customers.

Name, address, phone

number, account

number, date of birth,

email address,

account type, account

status, last four digits

of financial

instruments account,

sort code, account

balance, details of

account transactions

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

48 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

and liabilities, name of

funding source

provider, applicable

details of account

behaviour and copies

of all correspondence

(including without

limitation, all

correspondence

relevant for reporting

to credit reference

agencies) in each

case relating to

amounts you owe (or

another person owes)

to us.

Begbies Traynor Group plc (UK), Moore

Stephens LLP (UK), Moore Stephens Ltd (UK),

Moore Stephens International Ltd (UK),

Moorhead James LLP (UK), Comas Srl (Italy),

RBS RoeverBroennerSusat GmbH & Co. KG

(Germany), LLC Elitaudit (Russia), National

Recovery Service (Russia).

To investigate

(including, without

limitation, to carry

out asset and/or

site inspections

and/or business

evaluations) and/or

collect (and/or

assist with the

collection of) debt

from potentially

and actually

insolvent

customers

Name, address, phone

number, account

number, date of birth,

email address,

account type, account

status, last four digits

of financial

instruments account,

sort code, account

balance, details of

account transactions

and liabilities, name of

funding source

provider and copies of

all correspondence, in

each case relating to

amounts you owe (or

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

49 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

another person owes)

to us.

Webbank (USA)

Only for customers

who are also

customers of Bill

Me Later, Inc.: to

help with

accounting and

recovery services

Name, address, phone

number, account

number, date of birth,

email address,

account type, account

status, last four digits

of financial

instruments account,

sort code, account

balance, details of

account transactions

and liabilities, and

name of funding

source provider.

Digital River Inc. (USA) and Research in Motion

Limited (USA)

To enable you to

access and use

PayPal via a

mobile device (for

example mobile

phone or PDA).

Applicable details of

your account

information which are

transmitted as part of

your use of PayPal via

a mobile device.

mediafinanz AG (Germany)

To collect debt, to

request and

proceed

information from

and to Schufa,

Buergel and other

credit reference

and fraud agencies

for PayPal

Name, address, phone

number, account

number, date of birth,

business name, email

address, account type,

account status, last

four digits of financial

instruments account,

account balance,

details of account

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

50 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

transactions and

liabilities, name of

funding source

provider, credit score

received from agency,

account performance

data

Zyklop Inkasso Deutschland GmbH (Germany),

PNO inkasso AG (Germany), Hanseatische

Inkasso-Treuhand GmbH (Germany)

To collect and

manage debt, to

support collections

teams in case of

insolvent

customers

Name, address, phone

number, account

number, email

address, account type,

account status, last

four digits of financial

instruments account,

sort code and name of

funding source

provider, account

balance, date and

amount of last

payment, results of

creditworthiness

checks

Informa Solutions GmbH (Germany)

To request and

proceed

information from

and to Schufa,

Buergel and other

credit reference

and fraud agencies

in and from and to

ID Checker

Name, date of birth

business name, legal

form, address, email

address, company

registration number

and VAT number.

For the purpose of

verification of identity

also: other information

contained in

documents requested

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

51 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

by PayPal for Risk /

Compliance purposes.

For customers with a

German PayPal

account also: phone

number, length of time

at address, length of

time in business,

length of time with

PayPal, funding

instrument including

bank account and

credit /debit card

details and relevant

transaction

information, credit

score received on

behalf of PayPal from

a credit reference

agency, account

number, account type,

account status,

account balance,

details of account

transactions and

liabilities, negative

account performance

data.

P K Consultancy Limited (UK)

To assess risk and

help detect and

prevent potentially

illegal acts and

violations of

Name, address, phone

number, account

number, email

address, account type,

last four digits of

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

52 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

policies. financial instruments

account, account

balance, details of

account transactions

and liabilities, account

status and account

performance

information as

required for the

Purpose

Robertson Taylor Insurance Brokers Limited

(UK)

Consultation with

respect to risk

assessment of

specific merchants

and merchant

transactions

Name, address, phone

number, account

number, business

contact details,

domain name, email

address, account type,

account balance,

details of account

transactions and

liabilities, account

status and account

performance

information as

required for the

Purpose.

Yesmail Inc. (USA), Responsys (USA),

Silverpop Systems Inc. (USA) and e-Dialog, Inc.

(USA), Salesforce.com, Inc. (USA), Oracle

America Inc. (USA), Adobe Systems

Incorporated (USA), Teradata Corporation

To fulfil email

operations in

respect of the

PayPal services

(including, but not

limited to,

operations,

customer services,

Name, address, email

address, business

name, business

contact details,

domain name, account

status, account type,

account preferences,

type and nature of the

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

53 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

collections,

marketing

programmes and

promotions).

PayPal services

offered or used and

relevant transaction

and account

information.

Blue Media S.A. (Poland)

To verify identity

and ensure that a

user is a PayPal

account holder. To

process instant

funding requests

made by a user

through the Blue

Media services.

Name and email

address.

Consultix GmbH (Germany)

To assist in the

creation of PayPal

Business Accounts

for merchants on-

boarding through

their bank's or

other contract

partner payment or

service gateway.

All information

provided by the

merchant (directly or

via his/her bank or

other contract partner)

for the purpose of

creating his/her

PayPal business

account (including

without limitation email

address, address,

business name,

business contact

details and bank

account details).

Akamai Technologies Inc. (USA)

Content delivery

network – to

deliver PayPal

User IP address and

cookies.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

54 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

page content from

local servers to

users.

azionare GmbH (Germany)

To distribute prizes

in prize promotions

on Facebook.

Name, email address.

ITELLIUM mobile Solutions GmbH (Germany);

CartaSi S.p.A - Gruppo ICBPI (Italy)

To assist in the

production of

innovative payment

methods (e.g.

applications) and

processing of

payments through

such innovative

payment methods.

All account

information.

Trustwave Holdings Inc. (USA)

To provide PCI

compliance

validation services

for merchant

accounts and

merchant

integrations.

Business name,

address, account

number, merchant

type, compliance

program used, PCI

Level, PCI Status, PCI

Expiry, name, email

address, phone

number of merchant’s

contact person

Zoot Enterprises, Inc. (USA), Zoot Deutschland

GmbH (Germany), Zoot Enterprises Limited

(UK)

To process

technical

applications and to

provide a data and

document gateway

for account review,

testing and vetting

All account information

and documents

supplied by customers

such as proofs of

identity and address,

ownership of a funding

instrument, or other

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

55 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

purposes, and to

exchange user

information and

images of

documents proving

identity, address

and ownership of

funding instrument

with contracted

fraud and credit

reference

agencies.

documents requested

by PayPal and the

data contained therein

for Risk / Compliance

Credit purposes.

RR Donnelley and Sons Company (USA)

To provide printing

services such as

statements and

other printed

materials

Name, address, email

address, and account

information

Scorex (UK) Limited (UK)

To provide a

technology solution

to allow PayPal to

process, send and

receive credit

information of

users via its

contracted credit

reference

agencies.

Name, address, email

address, date of birth,

length of time at

address, phone

number, legal form,

length of time in

business, company

registration number,

VAT number (if

appropriate).

OXID eSales AG (Germany)

Services in

connection with the

development and

operation of a

payment system

All account information

and transaction

information (as

appropriate).

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

56 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

for stationary trade

(point of sale)

Ordermotion, Inc. (USA)

To collect data and

create/deliver

(direct to customer)

orders for the

PayPal Here

product (including,

without limitation,

the PayPal Here-

enabled device).

Name, address, email,

phone number, credit

card information and

PayPal Payer ID.

Ingram Micro, Inc. (USA) and Ingram Micro (UK)

Limited (UK)

To act as PayPal's

fulfilment

distributor for the

PayPal Here

product (including,

without limitation,

the PayPal Here-

enabled device).

Name and address.

Interxion Datacenters B.V.

To provide data

centre operations

support for the Bill

Safe credit

product.

All relevant account

information and

transaction information

(as appropriate).

Lattice Engines, Inc.

To develop and

optimize predictive

models.

Name of the merchant,

name of the contact

person, address, email

address, merchant

website URL

Interact CC Ltd (UK)

Providing

assistance with

PayPal service to

Customer name,

business name, phone

numbers, contact

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As of: July 1, 2015

57 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

customers email, website,

business industry,

shipping details, card

details for the payment

The unbelievable Machine Company GmbH

Hosting BillSafe

application on its

servers

All Account

information.

Group companies

PayPal Inc. (USA)

Acting on behalf of

PayPal for the

purposes of storing

and processing of

Account

information.

All Account

information.

PayPal Europe Services Limited (Ireland),

PayPal Malaysia Services Sdn Bhd (Kuala

Lumpur), PayPal Israel Ltd (Israel), PayPal India

Private Limited (India), PayPal (UK) Ltd (UK),

PayPal France S.A.S. (France), PayPal

Deutschland GmbH (Germany), PayPal Spain

SL (Spain), PayPal Italia Srl (Italy), PayPal

Nederland BV (Netherlands), PayPal European

Marketing SA (Switzerland), PayPal Polska Sp

Zoo (Poland), PayPal Bilisim Hizmetleri Limited

Sirketi (Turkey), PayPal International Sarl

(Luxembourg), PayPal SE (UK), Bill Me Later

Inc. (Germany), PayPal Information

Technologies (shanghai) Co., (China), PayPal

Australia Pty Limited (Australia), PayPal

Charitable Giving Fund (USA), PayPal Giving

Fund UK (UK), Tradera AB (Sweden),

Acting on behalf of

PayPal for the

purpose of

customer support,

risk assessment,

compliance and/or

other back office.

All Account

information.

PayPal Pte. Ltd. (Singapore) Acting for the All Account

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

58 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

account of PayPal

by entering into

and performing

non-customer

contracts which

involve customer

data.

information.

Commercial partners

eBay Inc. (USA), eBay Europe S.à r.l.

(Luxembourg), eBay Services S. à r.l.

(Luxembourg), eBay International AG

(Switzerland), eBay Corporate Services GmbH

(Germany), eBay France SAS (France), eBay

(UK) Limited (UK), eBay CS Vancouver Inc.

(Canada), eBay Partner Network Inc. (USA),

eBay Internet Support (Shanghai) Co Ltd

(China), eBay Enterprise Marketing Solutions

(USA) (formerly GSI Commerce, Inc (USA),

VendorNet Inc (USA), PepperJam Network

(USA), GSI Media Inc. (USA), M3 Mobile Co.,

Ltd. (Korea), MBS (USA), ClearSaleing (USA),

True Action Network (USA), True Action Studio

(USA)), GumTree.com Limited (UK), Kijiji

International Limited (Ireland), Kijiji US Inc.

(USA), mobile.de & eBay Motors GmbH

(Germany), Shopping.com Inc. (USA), Shopping

Epinions International Limited (Ireland),

Marktplaats B.V. (Netherlands), Private Sale

GmbH (Germany), StubHub, Inc. (USA), Viva

Group, Inc. (USA), StubHub Europe S.à r.l.

(Luxembourg), StubHub Services S.à r.l.

(Luxembourg), Viva Group, Inc. (USA),

ProStores Inc. (USA), MicroPlace, Inc. (USA),

To provide joint

customers content

and services

(including, but not

limited to

registration,

transactions,

failover for carrier

billing accounts,

and customer

support), to assess

risk, or to help

detect, prevent

and/or remediate

fraud, or other

potentially illegal

acts and violations

of policies, and to

guide decisions

about their

products, services

and

communications.

All Account

information.

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List of Third Parties (other than PayPal Customers) with Whom Personal Information May be Shared

As of: July 1, 2015

59 © 2015 PayPal. All rights reserved. PayPal (Europe) S.à r.l. et Cie, S.C.A.

Category Party Name and Jurisdiction (in brackets) Purpose Data Disclosed

Internet Auction Co., Ltd. (Korea), Via-Online

GmbH (Germany), Zong Inc.(USA) and

X.commerce, Inc. (USA). eBay Europe Services

Limited (Ireland), eBay GmbH (Germany)

Agencies

CSSF (Luxembourg), CNPD (Luxembourg),

Financial Ombudsman Service (UK),

Altroconsumo (Italy), European Consumer

Centre Network organisations (located in

Austria, Belgium, Bulgaria Czech Republic,

Cyprus, Denmark, Estonia, Finland, France,

Germany, Greece, Hungary, Iceland, Ireland,

Italy, Latvia, Lithuania, Luxembourg, Malta,

Netherlands, Norway, Poland, Portugal,

Romania, Slovakia, Slovenia, Spain, Sweden,

and the UK), Les Mediateurs du Net (France),

Risolvi Online (Italy) and BaFin (Germany)

To provide the

Agencies listed

with information

within their

authority (upon

their request) and

to respond to

queries and/or

investigations

instigated by users

or other

stakeholders in the

countries where

they have

jurisdiction.

All account information

With respect to the column titled, "Purpose", each third party, with the exception of the regulatory

agencies, certain of the payment processors and credit reference and fraud agencies and group

companies referred to at the end of this table, is carrying out the purpose to fulfil obligations which

PayPal has contracted with the entity to fulfil. The regulatory agencies are carrying out their purpose

in accordance with their regulatory objectives and requirements. Where explicitly specified in the

table, the payment processors and credit reference and fraud agencies may use the information in

their respective databases, and forward information to third parties for the purposes of fraud

prevention and the assessment of creditworthiness, in accordance with their respective terms.